UK Packaging EPR Compliance Guide for Businesses 2026

The United Kingdom’s Extended Producer Responsibility scheme for packaging, commonly called UK packaging EPR or pEPR, has changed how companies must manage packaging data, recycling obligations, and waste-management costs.

The rules affect UK organisations that import or supply packaging and meet the applicable turnover and packaging-volume thresholds. Depending on their size and activities, organisations may need to register with an environmental regulator, report packaging data, pay registration and disposal fees, assess packaging recyclability, and obtain evidence that packaging waste has been recycled.

The current framework is primarily established through the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. These regulations require relevant producers to register, collect and report packaging data, assess recyclability, meet recycling obligations, and contribute toward the costs of managing household packaging waste.

PackUK administers the UK-wide packaging EPR scheme on behalf of England, Scotland, Wales, and Northern Ireland. It sets applicable disposal-fee rates, manages important parts of the fee system, and publishes the Recyclability Assessment Methodology.

For businesses, UK packaging EPR is therefore not only an environmental reporting requirement. It can affect product cost, packaging design, supplier data, online sales, group reporting, audit readiness, and market access.

UK packaging EPR should not be confused with the EU Packaging and Packaging Waste Regulation, known as the PPWR.

UK packaging EPR applies under UK legislation to qualifying organisations supplying or importing packaging into the UK. The EU PPWR is an EU regulation that generally applies from 12 August 2026 and affects packaging placed on the EU market.

A UK business exporting packaged products to EU Member States may therefore need to manage both:

Official UK guidance warns UK exporters that EU PPWR requirements apply independently when products are placed on the EU market.

Companies selling in both regions need separate obligation maps rather than assuming one packaging registration or assessment covers both markets.

Extended Producer Responsibility places greater responsibility on organisations that supply or import packaging for the costs and management of that packaging after it becomes waste.

UK packaging EPR can require a qualifying organisation to:

• Determine whether it is a packaging producer
• Identify which packaging activities it carries out
• Register with the appropriate environmental regulator
• Report packaging data through the Report Packaging Data service
• Classify packaging by activity, type, class, material and weight
• Report where packaging is supplied and discarded within the UK
• Assess household and non-household packaging
• Conduct recyclability assessments where required
• Pay registration and scheme-administration charges
• Pay household packaging waste disposal fees where liable
• Obtain PRNs or PERNs to meet recycling obligations
• Maintain evidence explaining how packaging data was calculated

The objective is to make producers contribute more directly toward packaging collection, recycling, treatment, disposal, and public information costs.

A UK organisation needs to collect and report packaging data for a reporting year if all the following conditions apply:

• It is an individual business, subsidiary, or group
• Its annual turnover is at least £1 million
• It was responsible for importing or supplying more than 25 tonnes of packaging to the UK market during the previous calendar year
• It carries out at least one relevant packaging activity

The official guidance was updated in June 2026 and confirms these general applicability conditions.

A company below either the turnover or packaging-volume entry threshold may not be obligated under the main producer requirements. However, thresholds should be reassessed each year because changes in turnover, product volume, acquisitions, or group structure can change the outcome.

The obligations depend significantly on whether an organisation is classed as a small or large producer.

These classifications are based on both turnover and packaging tonnage, not employee numbers.

Main difference between small and large producers

Small producers must still register, collect data, and report it, but they do not pay waste disposal fees or purchase PRNs under the current small-producer rules.

A company may be responsible because of one or more packaging activities.

Official guidance identifies the following activities:

• Supplying packaged goods under the organisation’s own brand
• Placing goods into packaging
• Importing products in packaging
• Owning an online marketplace
• Hiring or loaning reusable packaging
• Supplying empty packaging

Packaging activities in practical terms

An organisation may carry out several activities simultaneously. The reported packaging data must be divided by the relevant activity rather than combined under one general category.

A brand owner can become responsible where packaging or packaged goods are supplied under its brand.

Examples include:

• A manufacturer selling products with its own company name
• A retailer selling private-label products
• A food company using its trademark on packaging
• A distributor placing its own brand on imported products

Brand responsibility should be assessed at packaging level. The presence of a brand, trade mark, product name, or other identifying mark may affect which organisation is treated as responsible.

Brand owners should maintain evidence showing:

• Which packaging bears their brand
• Who manufactured or filled it
• Who first supplied it in the UK
• Which entity reports the packaging
• Whether any supplier or packer reports part of the packaging separately

A company that places goods into packaging may be responsible for unbranded packaging it packs or fills.

Examples include:

• Filling unbranded bottles
• Packing goods into unbranded boxes
• Applying unbranded protective film
• Adding shipping packaging during fulfilment
• Packing products for another business

The responsibility can depend on whether another organisation’s brand is present and whether that other organisation meets the relevant large-producer criteria.

A packer or filler should clarify responsibility contractually and maintain packaging records even where another organisation is expected to report the packaging.

An organisation importing packaged goods into the UK may be responsible for the imported packaging.

The assessment can depend on:

• Whether the packaging is branded
• Whether the UK importer acts on behalf of another UK brand owner
• Who first owns the imported products in the UK
• Whether packaging is discarded by the importer
• Whether the products are supplied onward
• Whether another qualifying UK organisation assumes responsibility

Importers should not report only the product’s sales packaging. Relevant packaging may also include:

• Outer cartons
• Pallets
• Stretch wrap
• Protective film
• Dividers
• Inserts
• Labels
• Transport packaging
• Packaging around raw materials

Large producers are specifically instructed to include packaging surrounding raw materials in their data where relevant.

Businesses that manufacture or import empty packaging may have reporting obligations.

Examples include distributors supplying:

• Empty bottles
• Cans
• Jars
• Boxes
• Bags
• Films
• Pallets
• Crates
• Protective packaging

However, responsibility can shift where the packaging is supplied to a large packer, filler, or brand owner that assumes responsibility under the regulations.

Empty packaging suppliers need sufficient customer data to determine whether the recipient is obligated and whether the packaging should be reported by the supplier or customer.

Companies hiring or loaning reusable packaging may be in scope.

Common examples include:

• Pallet-pooling companies
• Reusable crate providers
• Drum-hire services
• Reusable transport-box providers
• Intermediate bulk-container services

Reusable packaging is generally reported when it is first supplied or put into use under the applicable reporting rules. It may need to be recorded both under the relevant packaging activity and as reusable packaging, depending on the reporting structure.

Companies should track:

• Packaging placed into service
• Material and weight
• Packaging class
• First-use date
• Hire or loan activity
• Returns
• Losses and replacements
• Reusable status

Under UK packaging EPR, an organisation owns an online marketplace where it operates a website or application allowing non-UK businesses to sell goods into the UK.

Such marketplace operators report the filled or empty packaging supplied into the UK through their platform by non-UK sellers. A website selling only goods from UK organisations does not fall within this specific marketplace activity, although the operator may still have responsibilities under another activity.

Online marketplace operators must also document the methodology they use to gather and calculate their packaging data. The methodology must generally be submitted by 1 April for the previous calendar year and regularly updated when products, sellers, or data sources change.

Marketplace data may need to cover

• Non-UK seller identity
• Product and SKU
• Packaging materials
• Packaging weights
• Units sold into the UK
• Sales period
• Destination nation
• Returned or cancelled sales
• Data-estimation methods
• Supplier or seller evidence
• RAM information where required

Marketplace operators need scalable seller-data controls because inaccurate weight assumptions multiplied across high sales volumes can materially affect reported tonnage.

Group structures require careful assessment.

Where multiple group companies import or supply packaging, the group must generally add together the turnover and packaging weight of all members carrying out packaging activities. If the group totals meet the small- or large-producer criteria, each relevant member may be required to comply even where that member would not meet the thresholds independently.

Groups may report:

• As one whole group
• Through individual subsidiaries
• Through a combination where some subsidiaries report independently

Even where a parent submits information, packaging data should normally remain separately identifiable by subsidiary.

Group-management risks

• Double-counting packaging between subsidiaries
• Omitting small subsidiaries after group thresholds are met
• Reporting packaging under the wrong legal entity
• Incorrectly consolidating imports and onward supplies
• Failing to account for mid-year acquisitions or disposals
• Using inconsistent packaging weights across subsidiaries

A controlled group methodology should define who reports each supply flow and how intercompany transactions are treated.

Affected producers need data showing how packaging was supplied, how it should be classified, what it is made from, and how much it weighs.

Core reporting fields include:

Government guidance confirms that packaging data is used to calculate both recycling obligations and waste disposal fees.

Packaging must be classified correctly because different classes can be treated differently in reporting.

Examples

Classification should be based on the packaging’s function rather than only its material or appearance.

Packaging EPR reporting is weight-based. Producers need reliable material weights rather than general estimates.

The main material categories include:

• Aluminium
• Fibre-based composite
• Glass
• Paper and card
• Plastic
• Steel
• Wood
• Other materials

The other category can include materials such as bamboo, ceramic, cork, copper, hemp, and rubber.

Packaging weight sources

Companies may obtain weight data through:

• Supplier specifications
• Packaging bills of materials
• Technical drawings
• Sample weighing
• Manufacturing records
• Laboratory reports
• Packaging-converter declarations
• Approved standard weights

Where estimates are used, the methodology should explain:

• Why an estimate was necessary
• Which sample or source was used
• Whether ancillary components were included
• How the estimate was applied across products
• How frequently the value is reviewed
• What controls prevent material errors

Supplier data should be linked to exact packaging versions because a small change in film thickness, bottle weight, label size, or carton grade can affect reported tonnage at scale.

Large producers must assess whether packaging is household or non-household.

Secondary and tertiary packaging must generally be treated as non-household. Primary and shipment packaging must generally be treated as household unless specific conditions are met and supported with sufficient evidence.

Primary or shipment packaging may be non-household where:

• It is supplied directly to a business or public institution that is the final user of the packaging
• The recipient removes and discards the packaging rather than supplying it onward
• The product is designed only for business or institutional use
• The packaging is not reasonably likely to be discarded in a household or public bin
• An importer brings packaging into the UK for its own use and discards it

If a producer cannot provide sufficient evidence, primary or shipment packaging must be reported as household packaging. Evidence supporting a non-household classification must be kept for at least seven years.

Useful non-household evidence

• Customer contracts
• Sales invoices
• Product specifications
• Distribution-channel records
• Statements from customers
• Product-use restrictions
• Evidence that packaging is removed before onward supply
• Business-only marketing materials
• Customer-type records
• Waste-management arrangements combined with proof of final use

A private waste collection arrangement alone does not automatically make packaging non-household.

Certain household packaging that commonly ends up in street or public bins must be reported in its specific category.

Examples may include packaging associated with products commonly consumed away from home. Producers should avoid reporting the same packaging twice as both ordinary household packaging and commonly binned packaging.

The official list is reviewed periodically, making it important to monitor current guidance for each reporting year.

Reporting frequency differs for large and small producers.

These deadlines are confirmed in the current official packaging-data guidance.

Businesses should collect packaging data continuously. Waiting until the reporting deadline can create problems where:

• Supplier weights are missing
• Product records have changed
• Sales data is incomplete
• Packaging versions cannot be matched
• Household classifications are unsupported
• Group transactions are unclear
• Marketplace sellers do not respond

A monthly or quarterly internal data-close process can reduce reporting pressure.

Nation data identifies where packaging is supplied or discarded within England, Scotland, Wales, or Northern Ireland.

An obligated producer may need to report nation data if it:

• Supplies filled or empty packaging directly to an end user
• Supplies empty packaging to a non-obligated or small organisation
• Hires or loans reusable packaging
• Operates an online marketplace through which non-UK organisations sell to UK users
• Imports packaged goods for its own use and discards the packaging

Nation data can require reliable customer-location and sales-channel information. Companies should determine whether the delivery address, customer location, billing address, store location, or another data point provides the most accurate basis.

The chosen methodology should be documented and applied consistently.

Obligated organisations must create an account, submit organisation information, upload packaging data, and register with the relevant environmental regulator.

The four regulators are:

The Report Packaging Data service is used to submit organisation details and packaging data. The environmental regulator reviews the registration, while PackUK administers the disposal-fee system.

Organisations should retain:

• Account-creation records
• Approved-person details
• Delegate access records
• Submitted organisation files
• Packaging data files
• Validation results
• Registration confirmations
• Registration-fee evidence
• Corrections and resubmissions

Correspondence with the regulator

Large producers can be liable for waste disposal fees on relevant household packaging.

The fees finance the costs of managing household packaging waste and other relevant scheme costs. Waste disposal fees apply to packaging classed as household packaging, commonly binned packaging, and glass household drinks containers under the applicable rules.

PackUK issued confirmed base fees for the first scheme year, 2025 to 2026:

These rates are year-specific and do not include regulator registration charges or the costs of meeting recycling obligations through PRNs and PERNs.

For 2026–2027, PackUK published illustrative rather than final Year 2 fee estimates in the source available at the time of this review. Businesses should therefore use current PackUK notices for budgeting rather than relying indefinitely on earlier estimates.

Large producers liable for household packaging waste disposal fees must use the Recyclability Assessment Methodology, or RAM, to assess and report the recyclability of relevant household packaging.

For the 2026 reporting year, producers should use RAM version 1.1. PackUK published the RAM 2027 methodology in July 2026 for packaging supplied during the 2027 reporting year.

RAM assesses packaging through factors including:

• Material classification
• Collection coverage
• Sortability
• Reprocessing
• Quality and use of the resulting recyclate
• Problematic components
• Separability of packaging components
• Take-back collection where relevant

Packaging receives a recyclability rating such as:

The RAM decision tree considers whether packaging is collected widely, can be sorted efficiently, can be reprocessed without technical or environmental problems, and produces usable recyclate.

RAM data companies should maintain

• Packaging ID and version
• Complete component structure
• Main material
• Plastic subtype where required
• Labels, adhesives, coatings and closures
• Separability information
• Collection route
• Sortation evidence
• Reprocessing evidence
• Assessment outcome
• Assessor and approval date
• Supporting supplier information
• Reassessment trigger

Recyclability assessments must be reviewed after relevant design, manufacturing, composition, or methodology changes.

From Year 2 of the scheme, household packaging disposal fees are modulated based on recyclability.

PackUK’s policy covers modulation from 2026 to 2029. Its purpose is to encourage more recyclable packaging design by creating higher cost exposure for less recyclable formats and more favourable treatment for better-performing packaging.

For Year 2, official illustrative guidance indicated that red-rated packaging would be charged at 1.2 times the amber rate, while greener packaging would receive more favourable treatment under the modulation structure.

This makes packaging design financially significant.

Businesses should prioritise formats with:

• Red RAM ratings
• Difficult-to-separate materials
• Full-body sleeves
• Problematic adhesives
• Incompatible coatings
• Dark or difficult-to-sort pigments
• Mixed-material structures
• Components that contaminate recycling streams
• Weak supporting evidence

Packaging redesign can take time, so businesses should not wait for an invoice before reviewing high-risk formats.

Large producers also need to meet packaging recycling obligations.

They do this by obtaining:

• Packaging Waste Recycling Notes, known as PRNs
• Packaging Waste Export Recycling Notes, known as PERNs

PRNs and PERNs are issued by accredited reprocessors and exporters as evidence that an equivalent quantity of packaging waste has been recycled.

Large producers must meet obligations separately for each packaging material. Excess evidence for one material generally cannot be substituted for a shortfall in another.

Business recycling targets

Only large producers need to obtain PRNs or PERNs. For obligations relating to a calendar year, the general deadline for acquiring the required evidence is 31 January of the following year.

Compliance schemes can obtain PRNs and PERNs on behalf of their members, but producers should still monitor the status of their obligations.

Producers can appoint an approved compliance scheme to help manage packaging EPR obligations.

A scheme may assist with:

• Registration
• Reporting packaging data
• Paying registration charges on behalf of members
• Calculating recycling obligations
• Obtaining PRNs or PERNs
• Preparing submissions
• Managing regulator communication

However, a compliance scheme cannot pay a producer’s waste disposal fees or certain administration charges on its behalf.

Companies should verify that the selected provider appears on the official compliance-scheme public register and establish clear contractual responsibilities for:

• Data accuracy
• Reporting dates
• Corrections
• PRN/PERN procurement
• Evidence retention
• Fee communication
• Audit support

Using a scheme does not remove the need for accurate internal packaging data.

A data methodology explains how a company gathers, calculates, verifies, and reports its packaging data.

It should cover:

• Data sources
• Product and SKU mapping
• Packaging specifications
• Weight calculations
• Estimation methods
• Sales and import data
• Returned products
• Group-company allocations
• Household and non-household decisions
• Nation data
• Marketplace seller data
• Reusable packaging
• Quality checks
• RAM assessments
• Corrections and version control

Online marketplaces must submit a methodology. Other producers may also need one depending on their reporting circumstances. Methodologies should be reviewed and updated regularly when suppliers, products, calculation methods, or packaging designs change. Methodologies submitted after 1 October 2025 must include RAM information where applicable.

A methodology should allow another qualified reviewer to reproduce the reported figures.

Large organisations may report eligible self-managed packaging waste.

This can include:

• Consumer waste collected through take-back schemes
• Organisation waste collected through backhauling or business systems
• Closed-loop packaging waste meeting specific conditions

Self-managed consumer waste may be used to offset relevant household packaging tonnage and reduce disposal-fee exposure, but the producer needs evidence that the waste was actually recycled during the reporting period by an accredited reprocessor or exporter.

Companies should retain:

• Collection records
• Waste-transfer evidence
• Material weight
• Recycling evidence
• Reprocessor or exporter accreditation
• Reporting-period confirmation
• Packaging-material match
• Calculation of the claimed offset

Waste merely sent for recycling is not necessarily enough; the required evidence must demonstrate that it was recycled.

Plastic Packaging Tax is separate from packaging EPR and should be assessed independently.

A business may need to register if it manufactures or imports at least 10 tonnes of finished plastic packaging components during the relevant 12-month or forward-looking period. Tax is generally payable on chargeable plastic packaging containing less than 30% recycled plastic.

From 1 April 2026, the tax rate is £228.82 per tonne of chargeable plastic packaging.

EPR vs Plastic Packaging Tax

A company can be liable for both systems.

Deposit Return Schemes for drinks containers are also separate but connected to EPR data.

England and Northern Ireland are introducing a DRS from 1 October 2027 for certain single-use PET plastic bottles and steel or aluminium cans between 150 ml and 3 litres. Scotland is working toward the same launch timeframe, while Wales approved a scheme beginning in October 2027 with its own regulatory approach.

The treatment of drinks containers within EPR can change once DRS systems become operational. PackUK’s RAM roadmap notes that relevant PET, aluminium, and steel drink containers can become subject to pEPR obligations where a DRS is not operational for the material.

Beverage companies should therefore maintain data on:

• Container material
• Capacity
• Country or UK nation
• DRS scope
• Deposit status
• Units placed on market
• Packaging weight
• Labels and barcodes
• EPR classification
• Effective dates

If an organisation stops being an obligated producer, it must notify the regulators within 28 days under the current guidance.

Step 1: Determine whether the thresholds apply

Calculate:

• Relevant annual turnover
• Packaging supplied or imported during the previous calendar year
• Group-level totals where applicable
• Whether the organisation is small or large

Step 2: Identify every packaging activity

Map whether the business acts as:

• Brand owner
• Packer or filler
• Importer
• First UK owner
• Empty packaging supplier
• Reusable packaging provider
• Online marketplace operator

Step 3: Build a complete packaging inventory

Include:

• Sales packaging
• Shipment packaging
• Secondary packaging
• Tertiary packaging
• Imported packaging
• E-commerce packaging
• Pallets and wrap
• Reusable packaging
• Packaging around raw materials

Step 4: Create component-level packaging data

Record:

• Material
• Weight
• Packaging class
• Packaging activity
• Household status
• Supplier
• Product or SKU
• Packaging version

Step 5: Assess household and non-household status

Collect evidence supporting every primary or shipment packaging item reported as non-household.

Step 6: Prepare RAM assessments

For relevant large-producer household packaging:

• Use the methodology for the correct reporting year
• Assess complete packaging units
• Store the rating and evidence
• Reassess after relevant changes

Step 7: Create reporting workflows

Set internal deadlines before the statutory dates:

• Large-producer half-year reporting
• Small-producer annual reporting
• Nation-data reporting
• Methodology submission
• PRN/PERN obligations
• Registration renewals

Step 8: Reconcile EPR and financial data

Connect packaging data to:

• Sales quantities
• Import quantities
• Returns
• Waste disposal fees
• Scheme costs
• PRN/PERN costs
• Plastic Packaging Tax
• Future DRS data

Step 9: Validate data before submission

Check:

• Missing weights
• Duplicate packaging
• Incorrect legal entities
• Unreasonable tonnage changes
• Household classifications
• Unsupported estimates
• Obsolete packaging versions

Step 10: Maintain an audit-ready evidence pack

Keep:

• Submitted files
• Data methodology
• Supplier specifications
• Weight evidence
• RAM assessments
• Non-household evidence
• Registration records
• Fee notices
• PRN/PERN records
• Approval history

UK packaging EPR requires companies to manage connected information across packaging items, materials, suppliers, products, legal entities, UK nations, reporting periods, recyclability assessments, registrations, and financial obligations.

ComplyMarket supports packaging and EPR compliance through structured processes for identifying producer responsibility, managing market-specific obligations, collecting supplier evidence, preparing reporting data, and maintaining audit-ready records.

ComplyMarket can help companies with:

• Producer-threshold and obligation assessments
• Small- and large-producer classification
• Packaging-activity mapping
• Group and subsidiary reporting structures
• Packaging inventory and bill-of-materials development
• Product-to-packaging mapping
• Material and weight data management
• Household and non-household assessments
• Supporting-evidence management
• Nation-data preparation
• RAM assessment records
• Registration and regulator-document tracking
• Reporting-period and deadline management
• PRN and PERN obligation visibility
• Disposal-fee data reconciliation
• Supplier declaration collection
• Packaging change control
• Online marketplace data management
• Audit-ready reporting packs

ComplyMarket’s platform approach helps connect packaging requirements to individual packaging items, supplier information, countries, supporting evidence, and compliance status rather than managing each obligation in a separate spreadsheet.

This is particularly valuable for companies with many SKUs, suppliers, packaging formats, sales channels, and reporting entities.